This guide is for people who have worked in both the United States and the United Kingdom and want to know what they will receive from each state system, when, and how it is taxed. In brief: you can usually earn both a US Social Security benefit and a UK State Pension, each paid on its own record; the 1984 US–UK agreement stops you paying into both systems for the same work and can help you qualify; and the 2001 income tax treaty generally taxes these benefits only in the country where you live.
Can I get both Social Security and a UK State Pension?
Yes. Each country pays a benefit based on your record in its own system. If you have enough US work credits you receive Social Security. If you have enough UK qualifying years you receive the UK State Pension. Receiving one does not stop you receiving the other, and since the 2025 repeal of the Windfall Elimination Provision a UK pension no longer reduces your US benefit[19].
The systems differ. Social Security is earnings-related, based on your highest 35 years of indexed US earnings. The new UK State Pension is closer to flat-rate: you get a proportion of the full amount for each “qualifying year”, a tax year with enough National Insurance (NI) contributions paid or credited. So a missing UK year costs a fixed slice, while a missing US year matters only if it would have been among your 35 highest-earning years.
| Feature | US Social Security | UK new State Pension |
|---|---|---|
| Basis | Earnings-related (highest 35 years of indexed earnings) | Flat-rate, proportional to qualifying years |
| Minimum to qualify | 40 quarters of coverage (“credits”)[14] | Usually 10 qualifying years[3] |
| For the full amount | No fixed number of years; maximum at full retirement age $4,152 a month in 2026[15] | 35 qualifying years (if your record started after April 2016) for £241.30 a week[2] |
| Earliest claim | 62, permanently reduced[16] | State Pension age only (66, rising to 67)[4] |
| Reward for waiting | 8% a year from 67 to 70[17] | 1% per 9 weeks, just under 5.8% a year[5] |
| Annual increase | Cost-of-living adjustment: 2.8% for 2026[15] | Triple lock: 4.8% in April 2026 (£230.25 to £241.30)[1] |
| Working while claiming | Earnings test before full retirement age ($24,480 exempt in 2026)[15] | No earnings test |
What does the US–UK totalisation agreement do?
The agreement decides which country’s social security taxes you pay, so the same work is not taxed twice, and lets each country count the other’s coverage when you are short of the minimum to qualify. It was signed in London on 13 February 1984 and took effect on 1 January 1985, with the benefit provisions following on 1 January 1988[13].
Contributions. As a general rule you pay into the system of the country where you work. An employee sent temporarily by their employer to the other country stays in the home system if the assignment is not expected to last more than five years (Article 4.2)[13]. Self-employed people are covered by the country where they live[31].
Benefits. For Social Security, the SSA can combine US and UK periods only if you have at least six US quarters of coverage (Article 8). If the combined record meets the 40-quarter test, the US pays a partial benefit that reflects the share of your career spent under US coverage[13][14]. On the UK side, Article 9 of the agreement was written for the old basic State Pension: it treats each US quarter of coverage after 5 April 1975 as 13 weeks of UK contributions at the lower earnings level, for calculating entitlement[13]. The USA is one of the UK’s social security agreement countries[30], and a 2016 Order extended the UK’s agreements, including the US one, to the new State Pension. Under it, the UK takes account of periods completed under the other country’s system only to decide whether you have the minimum number of qualifying years, and pays the new State Pension based only on UK contributions paid, credited or treated as paid[33]. GOV.UK says the same: time abroad in an agreement country may help you make up the 10 qualifying years, but the amount paid is based only on the qualifying years in your UK NI record[3].
Totalisation helps you qualify; it does not add value. With eight UK qualifying years, US coverage may help you meet the 10-year minimum, but the pension is still worked out on eight years. Ask the International Pension Centre how this applies to your record before relying on it.
How much UK State Pension will I get, and when?
For people reaching State Pension age now, the full new State Pension is £241.30 a week in 2026/27, about £12,548 a year. That needs 35 qualifying years, and at least 10 are usually needed to get any pension at all[1][2][3]. Between 10 and 35 years, you get 1/35 of the full rate for each qualifying year. That is about £6.89 a week per year at 2026/27 rates (our arithmetic).
Records from before April 2016 follow transitional rules: people who were contracted out may need more than 35 years, and some receive a “protected payment” on top of the full rate[2]. Only your own forecast is reliable.
State Pension age is 66 and is rising to 67. People born between 6 April 1960 and 5 March 1961 reach it at 66 plus a number of months. Anyone born between 6 March 1961 and 5 April 1977 reaches it at 67. Under the Pensions Act 2007, it rises to 68 between 2044 and 2046[4]. There is no early claim. You can defer, and for people who reached State Pension age after 6 April 2016 each nine weeks of deferral adds 1%, just under 5.8% for a full year[5].
Living in the US. The USA is on the government’s list of countries where the annual increase is paid[7]. Elsewhere pensions can be frozen at the rate first paid; GOV.UK notes there is no yearly increase in Canada or New Zealand, for example.
What changed for voluntary National Insurance in April 2026?
From 6 April 2026, voluntary Class 2 contributions can no longer be paid for periods abroad, with narrow exceptions. Anyone abroad who wants to fill a year must pay Class 3. Anyone applying for the first time must also have lived in the UK for 10 continuous years, or have 10 years of qualifying contributions. The old test was three years[8][9][12]. The measure was announced at Budget 2025[8].
| Rule | 2025/26 and earlier years | 2026/27 onward |
|---|---|---|
| Class 2 (£3.65 a week in 2026/27) | Available if you worked in the UK immediately before leaving and work abroad | Not available for periods abroad (limited exceptions) |
| Class 3 (£18.40 a week in 2026/27) | Available | The only voluntary option abroad |
| Connection test | 3 continuous years’ UK residence or 3 years’ contributions | 10 continuous years’ residence or 10 years’ qualifying contributions (not counting voluntary contributions paid while abroad) |
| Cost of a full year | Class 2 at the rate for that year | 52 × £18.40 = £956.80 (our arithmetic) |
Rates from GOV.UK[10]. The government estimates that about 46,000 people were paying voluntary Class 2 abroad, and that Class 3 costs them £767 a year more[8].
Three details matter. First, the change does not affect paying Class 2 or Class 3 for earlier tax years, which can still be paid on the old basis[8]. You can normally pay for the past six years, and each year’s deadline is 5 April[11]. Second, there is a transitional window. People who applied to pay for 2024/25 or 2025/26 on or before 5 April 2026 can keep the old three-year test for 2026/27 if they pay those contributions on or before 5 April 2027 and apply for Class 3 for 2026/27 on or before 5 April 2027. HMRC describes this as existing Class 2 payers having until 6 April 2027 to move to Class 3 without meeting the new criteria[8][9]. Third, Class 3 builds State Pension entitlement only, not other contributory benefits[8].
Even at Class 3 rates, a year can be good value, but only if it actually increases your pension. Check your forecast first.
How much Social Security will I get, and when should I claim?
Your benefit at full retirement age (the “primary insurance amount”) comes from your US earnings record. For anyone born in 1960 or later, full retirement age is 67. You can claim from 62 with a permanent 30% reduction, or wait until 70 and gain 8% for each year after 67[16][17]. For 2026 the maximum benefit at full retirement age is $4,152 a month and the average retired-worker benefit is $2,071, after a 2.8% cost-of-living adjustment[15].
| Claim at | Adjustment | Monthly benefit | Annual benefit |
|---|---|---|---|
| 62 | −30% | $1,400 | $16,800 |
| 67 (full retirement age) | none | $2,000 | $24,000 |
| 70 | +24% | $2,480 | $29,760 |
Leaving aside investment returns, tax and the fact that both amounts rise with inflation, the total received from a claim at 70 overtakes the total from a claim at 62 at about age 80½, and overtakes the total from a claim at 67 at about 82½. ONS figures suggest a 65-year-old in the UK in 2023 can expect to live about another 20 years (men) or 22½ years (women) on average[27]. For a couple, what matters is how long the longer-lived spouse survives.
Several cross-border factors can change the answer:
- Working in the UK before 67. If you claim early and keep working in the UK in work not covered by US Social Security, the SSA’s “foreign work test” can withhold your benefit for each month in which you work more than 45 hours[20].
- Currency. A sterling spender receiving dollars takes on exchange-rate risk every month. See our guide to GBP/USD currency risk in retirement.
- Trust fund outlook. The 2026 Trustees Report projects the combined trust funds can pay all scheduled benefits until 2034 and 83% after that (the retirement fund alone, late 2032 and 78%)[21]. These are current-law projections, not a forecast of what Congress will do; testing a reduced benefit is prudent.
- Payments abroad. US citizens and UK nationals can generally be paid while living in the UK, and the five-year US residence requirement for non-citizen dependants and survivors does not apply to residents of agreement countries such as the UK[20].
Does a UK pension still reduce my Social Security?
No, not for benefits payable from January 2024. The Social Security Fairness Act, signed on 5 January 2025, ended the Windfall Elimination Provision (WEP) and the Government Pension Offset (GPO). December 2023 was the last month either applied[19]. WEP used to cut the Social Security of people who also had a pension from work not covered by US Social Security, and a UK State Pension could count as one. GPO reduced spousal and survivor benefits for people with certain government pensions. If an old WEP reduction still shows on your record, ask the SSA to review it.
Where are these benefits taxed?
Under Article 17(3) of the 2001 US–UK income tax treaty, social security paid by one country to a resident of the other is taxable only in the country where the recipient lives. Article 1(5) lists Article 17(3) among the exceptions to the saving clause, the rule that normally lets the US tax its citizens as if the treaty did not exist[22]. In practice, a US citizen living in the UK is exempt from US tax on Social Security, and IRS Publication 915 lists the UK among the countries where this applies[23]. HMRC’s treaty notes agree[24].
| Recipient | Benefit | Taxed in | Notes |
|---|---|---|---|
| UK resident (any nationality, including US citizens) | US Social Security | UK only | Art. 17(3), which the saving clause does not override[22]. The US 85% cap does not apply in the UK. HMRC generally taxes the full amount of foreign benefit income arising[25]. |
| US resident (any nationality) | UK State Pension | US only | Art. 17(3). Paid gross by the UK. |
| US resident | US Social Security | US | Up to 85% taxable. Base amounts $25,000 single, $32,000 joint[23]. |
| UK resident who is also a US citizen | UK State Pension | UK; the US may also tax as a citizen | Art. 17(3) covers payments to residents of the other country, so it does not deal with this case. The US normally gives credit for UK tax. Confirm the treatment with your US tax preparer. |
So a UK resident pays UK tax on the whole Social Security benefit, which can mean more tax than in the US. And the State Pension is paid gross but uses up your personal allowance. The full new State Pension of about £12,548 a year uses almost all of the £12,570 personal allowance[26] (our arithmetic), so private pension, IRA and Social Security income on top is taxed from the first pound, at 20% in the basic-rate band up to £50,270. Tax rules change and depend on individual circumstances.
What happens to these benefits when one spouse dies?
Social Security is generous to survivors. The UK new State Pension mostly is not. A surviving spouse can receive Social Security survivor benefits from 60, starting at 71.5% of the deceased’s benefit and rising to 100% at the survivor’s full retirement age. There is also a one-off $255 death payment[18]. While both are alive, a spouse can receive up to half of the worker’s benefit[28]. Non-citizen spouses living in the UK are not caught by the five-year US residence rule[20].
Under the new UK State Pension, each person’s pension is mainly their own. A survivor can inherit half of a protected payment, and some or all of any extra State Pension from deferral, but broadly only if the marriage or civil partnership began before 6 April 2016. Nothing is inherited if the survivor remarries or forms a new civil partnership before reaching State Pension age[6].
So a couple with two UK State Pensions loses one entirely on the first death, while a couple with Social Security may keep the larger benefit, which is one reason the higher earner’s claiming age matters. Our guide to estate planning across the US and UK covers what happens to other assets.
How do state benefits fit with pension and IRA withdrawals?
Most plans treat state benefits as lifelong, inflation-linked base income and use investments for the gap above them and the years before they start. For cross-border households, the withdrawal order has tax effects in two countries.
- The bridge years. Someone retiring at 60 may have up to seven years before the UK State Pension starts, and more if they defer Social Security to 70. Those years are paid for from pensions, ISAs, IRAs or taxable accounts. The UK normal minimum pension age rises from 55 to 57 on 6 April 2028[32], so check when each pot can be accessed.
- Low-income years. Years with little taxable income before state benefits start can be a chance to draw taxable pension or IRA income, or realise gains, at lower rates. How a US Roth conversion is treated in the UK is a specialist question. See US retirement accounts when you live in the UK.
- Required minimum distributions. Traditional IRAs and 401(k)s must start paying out at 73 under current rules (75 for those born in 1960 or later)[29]. For a UK resident these withdrawals are added to State Pension and Social Security income, which can push total income into the 40% band.
- Delaying Social Security as a hedge. Drawing more from investments while waiting until 70 exchanges portfolio risk for a larger lifelong, inflation-linked income.
None of these is a rule; whether an order suits you depends on your circumstances, so take advice. Our guide to how much you can spend in retirement covers the spending side.
Worked example: state benefits in a cross-border plan (computed in Edale’s planner)
Fictional household, for illustration only. Alex (50) and Sam (48) earn about £94,000 and £38,000, live in the UK, and plan to retire at 60. They hold £430,000 in pensions, plus an ISA, a UK general investment account, a US brokerage account and a £650,000 home. Planner results use the assumptions in Edale’s planner and are not guaranteed. The State Pension and Social Security arithmetic further down is ours, uses official 2026 rates, and was not produced by the planner.
| Measure | Result |
|---|---|
| Share of 300 simulated market histories in which the plan stays whole | 66.7% |
| Extra spending the plan could support each year and still be met | about £10,900 |
| Usable money at age 85 | about £1.14m |
For a couple retiring at 60, spending comes from investments until State Pension age; after that, each state benefit reduces what the portfolio must provide. That is why a one-in-three chance of falling short can move noticeably when benefit amounts or start dates change.
Illustrative arithmetic 1: filling a UK gap with Class 3. Suppose Sam lived in the US for some years and has gaps that would genuinely add to the pension, and is eligible to pay for them. A year of Class 3 costs £956.80 at the 2026/27 rate (some earlier years are charged at their original rate). It adds about 1/35 of £241.30 a week, roughly £358 a year before tax. The cost would be recovered in under three years of receiving the pension, or about three and a third years after 20% tax.
Illustrative arithmetic 2: Alex’s Social Security. If Alex had a US record worth $2,000 a month at 67, claiming at 62 would pay $1,400 a month and waiting to 70 would pay $2,480, before cost-of-living increases. As a UK resident, Alex would pay UK income tax on the whole benefit, and no US tax, under the treaty.
In practice an adviser enters each forecast with a start age and compares claiming choices as scenarios side by side, including the tax and the survivor’s income.
How the Edale Wealth Hub helps
The value of state benefits depends on everything around them: retirement dates, bridge years, which country taxes the income and what the survivor keeps. Edale’s planner brings these together for an adviser and client.
- Both systems in one plan. Social Security and the UK State Pension sit alongside US accounts (401(k), IRAs, Roth IRAs, brokerage) and UK ones (SIPPs, workplace and defined benefit pensions, ISAs, general investment accounts). The household is modelled year by year to age 100 and beyond, in whichever currencies it uses.
- Tax in both countries. The plan applies UK income tax, including Scottish rates, and US federal tax, and shows how they interact for US persons through foreign tax credits and treaty treatment. The result is what the household actually keeps.
- Timing questions as scenarios. Retiring earlier or later, first death, moving between the UK and the US, and alternative withdrawal orders can each be run as a what-if and compared side by side with the base plan.
- Risk around the benefits. Monte Carlo analysis, replays of real market history, twelve named GBP/USD and GBP/EUR currency episodes, and longevity tested against ONS life and healthy-life expectancy show how exposed a plan is while it waits for state benefits and afterwards.
- Tax rules by year. Thresholds can be held at today’s levels or applied year by year as legislated or announced.
There are limits. The planner uses the benefit amounts and start ages you enter. It does not fetch your NI record or SSA earnings history, and it does not decide whether a voluntary contribution is allowed or worthwhile. You still need a State Pension forecast from the UK government and a Social Security statement from the SSA. Tax outputs are summaries to share with your accountant or tax preparer, not tax returns. Edale does not prepare US tax returns. To talk this through, arrange a conversation or read about the cashflow planner.
Frequently asked questions
Can I receive both US Social Security and the UK State Pension?
Yes. Each country pays a benefit based on your record in its own system, and you can receive both. Since the Social Security Fairness Act repealed the Windfall Elimination Provision for benefits payable from January 2024, a UK State Pension no longer reduces your Social Security. You need 40 US credits (or at least six, combined with UK periods, under the totalisation agreement) and usually 10 UK qualifying years.
Is the UK State Pension frozen if I retire to the United States?
No. The USA is on the UK government’s list of countries where the State Pension goes up each year, because of the social security agreement between the two countries. A UK pensioner living in the US receives the same annual increases as one living in the UK. There is no yearly increase in some other countries, including Canada and New Zealand.
Can I still pay voluntary Class 2 National Insurance from abroad?
Not for tax years from 6 April 2026. Voluntary Class 2 for periods abroad has been withdrawn, apart from narrow exceptions, and Class 3 (£18.40 a week in 2026/27) is the option. New applicants need 10 years of UK residence or contributions. Earlier tax years can still be paid on the old basis within the usual six-year window.
Do US years count towards my UK State Pension?
They can help you qualify, but they do not increase the amount. Under the agreement, US coverage can be taken into account for UK entitlement conditions, but GOV.UK says the State Pension paid is based only on your UK qualifying years. Ask the International Pension Centre how it applies to your record.
Is my Social Security taxed in the US if I live in the UK?
Generally no. Article 17(3) of the US–UK treaty makes social security taxable only in the recipient’s country of residence, and this applies to US citizens too because it is an exception to the saving clause. IRS Publication 915 confirms the exemption for UK residents. The UK taxes the benefit instead, at UK rates.
When should I claim Social Security if I live in the UK?
There is no single right age. Claiming at 62 cuts the benefit by 30% for those born in 1960 or later. Waiting from 67 to 70 adds 8% a year. The right choice depends on health, a spouse’s survivor benefit, other income, UK tax, currency risk and whether you still work, because of the foreign work test. Take advice on your own circumstances.
What does a widow or widower receive from each system?
Social Security can pay a surviving spouse between 71.5% of the deceased’s benefit at 60 and 100% at full retirement age. The new UK State Pension is largely individual. A survivor may inherit half of any protected payment and some deferred extra, broadly only if the marriage began before 6 April 2016. Household income often falls noticeably after the first death.
Sources
- DWP — Benefit and pension rates 2026 to 2027 (accessed September 2026)
- GOV.UK — The new State Pension: what you’ll get (accessed September 2026)
- GOV.UK — The new State Pension: if you’ve lived or worked abroad (accessed September 2026)
- GOV.UK — State Pension age timetable (accessed September 2026)
- GOV.UK — Delay (defer) your State Pension: if you reach State Pension age on or after 6 April 2016 (accessed September 2026)
- GOV.UK — Inheriting or increasing State Pension from a spouse or civil partner (accessed September 2026)
- GOV.UK — Countries where we pay an annual increase in the State Pension (accessed September 2026)
- HMRC — Voluntary National Insurance contributions abroad from 6 April 2026 (accessed September 2026)
- GOV.UK — Voluntary National Insurance: if you live or work abroad (accessed September 2026)
- GOV.UK — Voluntary National Insurance: rates (accessed September 2026)
- GOV.UK — Voluntary National Insurance: deadlines (accessed September 2026)
- HMRC National Insurance Manual — NIM33204: entitlement to pay voluntary Class 3 contributions from 6 April 2026 (accessed September 2026)
- Social Security Administration — U.S.–U.K. Social Security Agreement (text) (accessed September 2026)
- Social Security Administration — U.S. International Social Security Agreements (accessed September 2026)
- Social Security Administration — 2026 Cost-of-Living Adjustment fact sheet (accessed September 2026)
- Social Security Administration — Benefit reduction for early retirement (accessed September 2026)
- Social Security Administration — Delayed retirement credits (accessed September 2026)
- Social Security Administration — What you could get from survivor benefits (accessed September 2026)
- Social Security Administration — Social Security Fairness Act: WEP and GPO update (accessed September 2026)
- Social Security Administration — Your Payments While You Are Outside the United States (Publication 05-10137) (accessed September 2026)
- Social Security Administration — Board of Trustees: projection for combined trust funds (June 2026) (accessed September 2026)
- US Treasury — Convention between the US and the UK for the avoidance of double taxation (signed 24 July 2001) (accessed September 2026)
- IRS — Publication 915, Social Security and Equivalent Railroad Retirement Benefits (accessed September 2026)
- HMRC Double Taxation Relief Manual — DT19853: USA notes (accessed September 2026)
- HMRC Employment Income Manual — EIM76009: taxable foreign benefits (accessed September 2026)
- GOV.UK — Income Tax rates and Personal Allowances (accessed September 2026)
- ONS — Past and projected period and cohort life tables: 2022-based, UK, 1981 to 2072 (accessed September 2026)
- Social Security Administration — Family benefits (accessed September 2026)
- IRS — Retirement plan and IRA required minimum distributions FAQs (accessed September 2026)
- HMRC — Guidance on social security abroad (NI38) (accessed September 2026)
- Social Security Administration — Totalization agreement with the United Kingdom (accessed September 2026)
- HMRC — Increasing normal minimum pension age (accessed September 2026)
- legislation.gov.uk — The Social Security (Reciprocal Agreements) Order 2016 (SI 2016/158) (accessed September 2026)